leases for polling locations. I acknowledge that much work is done also before and after elections. I have been mindful of the logistical, time-constraining considerations faced by EC. The ROs and others are extremely busy during the 36-day election period. [24] Parliament has provided for the accessibility of elections in numerous sections of the CEA, including subsection 121(1) which states that "a polling station shall be in premises with level access." The term "level access" is not defined in the statute. In EC's CPS manual it is defined as "flat access..." Guidelines, not legislatively mandated, indicate that the benchmark for a ramp slope is 1:12 (1" rise per every 12" long). I appreciate that "level access" is a sub-category of "barrier-free access". While the lack of level access is a major barrier, it is by no means the only barrier faced by those with mobility impairments. [25] As well, the CEA does not prohibit EC from providing further and greater accommodations than simply "level access", and it has done so. This may be seen in its policies, guidelines, manuals, training materials and as outlined on its website, which involves "barrier-free" accommodations for mobility impairments beyond "level access" and for non-mobility impairments. EC's Policy on Barrier-Free Access to Voting reads: "Offices and polling sites established and maintained by returning officers during an electoral event must in all respects provide barrier-free access." (EC's bolding) In its module on accessibility in its training session for ROs, in one of the Power Point slides, EC says one of the goals of the session is for ROs to be able to "[E]nsure barrier free access to the electoral process." EC's Accessibility Information sheet for St. Basil's Church lists many criteria, including accessibility issues other than "level access", such as signage and adequate heating. Mr. Roussel also testified that EC considers many factors other than the "level" or flat access of premises when determining the suitability of polling stations under subsection 121(1) of the CEA, including factors that I would characterize as "barrier-free" in nature. [26] Parliament has also legislated an exception in the CEA to providing "level access": subsection 121(2). It sets out the procedure whereby a RO may obtain dispensation from the requirement upon prior approval of the CEO, if the RO is unable to secure suitable "level access" premises. Mr. Roussel testified that seeking this exemption is a last resort and rare. Any such exemptions are reported by the CEO in his post-election report to Parliament. Instead, EC has paid for the installation of temporary, and formerly also permanent, ramps to overcome barrier issues. In the 2008 general election, 122 ramps were installed across Canada, at a total cost of $127,000. Selection of Polling Locations [27] It is the RO's responsibility to select the many polling locations within the district. As Mr. Roussel testified, the ROs conduct onsite evaluations to the best of their ability. There is an inventory or computer data base of over 27,000 locations across Canada. The last onsite inspection of St. Basil's Church appears to have been done on May 20, 2002. The document indicates that the Church met the section 121 "level access" requirements of the CEA. Mr. Roussel also averred that ROs are not architects or construction 2010 CHRT 4 (CanLII) Accessibility Requirements